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75 results for “transfer pricing”+ Section 19clear

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Key Topics

Section 260A23Section 26020Addition to Income20Section 10A16Section 9611Deduction11Section 10(20)10Section 1519Exemption9

Principal Commissioner of Income Tax-3 vs. M/s Satyasai Bhavani Hsopitals Private Limited

ITTA/537/2015HC Telangana02 Nov 2015

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

Section 260

Transfer Pricing Officer (TPO) or Dispute Resolution Panel (DRP) which comprises of three Commissioners and the Revenue or the assessee may feel dissatisfied, because of the reversal or modification of such findings by the Tribunal resulting in leaving out of certain comparables or adding on of certain comparables for determining the ‘Arm’s Length Price’ in the hands

M/S.R.S.RANGADAS vs. THE ASST.COMMISSIONER OF INCOME TAX

Appeals are disposed of, with no order as to costs

ITTA/406/2005HC Telangana19 Oct 2022

Bench: C.V. BHASKAR REDDY,UJJAL BHUYAN

Section 2(47)Section 271(1)(c)

Showing 1–20 of 75 · Page 1 of 4

Section 80P(2)(a)8
Comparables/TP8
Section 47
Section 45(1)
Section 48
Section 54F

price bargained for. Nor has it any necessary reference to the market value of the capital asset which is the subject-matter of the transfer." The ratio was followed in Commissioner of Income Tax, Calcutta versus Gillanders Arbuthnot and Company, [1973] 87 ITR 407 (SC). 23. The aforesaid two decisions did not examine the proviso to Section

Commissioner of Income tax-VI vs. M/s. Narpat Girji Constructions,

The appeal is allowed

ITTA/19/2015HC Telangana25 Mar 2015
Section 449Section 456Section 456(1)Section 456(2)Section 483

transferred into their name immediately, failing which, the Institution would not be recognized. It was also said that they were willing to pay - 13 - OSA No. 19 of 2015 the present market price of the said land and buy the scheduled property situated in 6.3 acres, immediately. 19. Prayer was sought for a direction to the Official Liquidator to sell

M/S VAIBHAV vs. JOINT COMM. OF INCOME TAX RANGE 3 HYD

Appeal is allowed and the judgments and decrees passed by the

ITTA/58/2002HC Telangana14 Sept 2022

Bench: The Learned Trial Court) Was Allowed & The Judgment & Decree Dated 12.12.2000, Passed By Learned Senior Sub Judge, Kullu Was Set-Aside. (Parties Shall Hereinafter Be Referred To In

For Appellant: Mr. Bimal Gupta, Sr. Advocate with

Section 54 of the Transfer of Property Act, 1882 (“the Act”, for short) defines “sale” as “a transfer of ownership in exchange for a price paid or promised or part-paid and part-promised”. If the intention of the parties was that the title should pass on execution and registration, the title would pass to the 19

The Commissioner Of Income Tax (Central) vs. Madhu Enterprises

ITTA/455/2017HC Telangana06 Jul 2017

Bench: SANJAY KUMAR,GUDISEVA SHYAM PRASAD

price of goods taxable under Section 10 of the Act; ii) Transaction falling under Section 5(2), Section 6-A and Section 6(2) of the CST Act, 1956, iii) Value of transfer of a business as a whole iv) [ xxx] (iii) This sub-rule is not applicable, if the VAT dealer is making exempt transactions. 22. By comparing

S.l. Shiva Raj vs. Commissioner of Income Tax,

ITTA/134/2016HC Telangana14 Jul 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

price of goods taxable under Section 10 of the Act; ii) Transaction falling under Section 5(2), Section 6-A and Section 6(2) of the CST Act, 1956, iii) Value of transfer of a business as a whole iv) [ xxx] (iii) This sub-rule is not applicable, if the VAT dealer is making exempt transactions. 22. By comparing

The Commissioner of Income Tax-III vs. Smt. Raj Kumari

Accordingly are partly allowed

ITTA/23/2008HC Telangana28 Mar 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

transfer and, therefore, respondent no. 1 or his father had become full owner of the suit land. 37 LPA-22-2008+ 39. Aforesaid aspects show that the tahsildar had taken into account certain documents and considered the matter and rejected the application. It appears that neither the appellate nor the revisional authority has taken into account various facts and circumstances

Commissioner of Income Tax-II vs. M/s.Jayalakshmi Chits

ITTA/211/2008HC Telangana23 Mar 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

price  lower than the market rate. If that be so,  the   question   of   inflating   the   loss   by  transferring   the   shares   to   group   company  would   not   arise.   Under   ordinary  circumstances,   it   is   always   open   to   the  assessee in his own wisdom to either hold on  to certain bunch of shares or to sell the  same to avoid further loss

The Commissioner of Income Tax-II, vs. M/S Gulf Oil Corporation Pvt. Ltd.,

ITTA/195/2008HC Telangana23 Mar 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

price  lower than the market rate. If that be so,  the   question   of   inflating   the   loss   by  transferring   the   shares   to   group   company  would   not   arise.   Under   ordinary  circumstances,   it   is   always   open   to   the  assessee in his own wisdom to either hold on  to certain bunch of shares or to sell the  same to avoid further loss

The Commissioner of Income Tax - VI vs. M/s. Manikanta Iron AND Hardware

ITTA/196/2008HC Telangana02 Mar 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

price  lower than the market rate. If that be so,  the   question   of   inflating   the   loss   by  transferring   the   shares   to   group   company  would   not   arise.   Under   ordinary  circumstances,   it   is   always   open   to   the  assessee in his own wisdom to either hold on  to certain bunch of shares or to sell the  same to avoid further loss

The Commissioner of Income Tax-V vs. The Armed Forces Officers Co.Op Housing Society Ltd

ITTA/78/2007HC Telangana27 Aug 2011

Bench: CHALLA KODANDA RAM,G.CHANDRAIAH

price, and since all of these aspects are found in the two documents dated 25.9.2006 Ex.P-1 and Ex.P-2, hence I hold that these documents are complete contracts under the Indian Contract Act. CS(OS) No. 78/2007 Page 11 of 43 12(i) The argument urged on behalf of the learned counsel for the defendants that these documents cannot be said

Commissioner of Income Tax vs. Sri Chirla Rama Reddy, Contract

Appeal is dismissed with costs

ITTA/70/2007HC Telangana23 Mar 2016

Bench: The Hon’Ble Mr. Justice N.K.Sudhindrarao R.S.A.No.70/2007

Section 100

19 of 1996 valid? 4. Can there e a declaration when no consequential relief is prayed for in the light of Section 344 of Specific Relief Act? 37. In addition to it I found it necessary to frame additional substantial questions of law as under: (i) Whether non registration of document after non registration of an instrument of conveyance after

The Commissioner of Income Tax vs. M/s.Sri Lakshmi Narasimha Construction

ITTA/211/2006HC Telangana21 Mar 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

Section 247Section 98

price paid or promised, or of money, a share of crops, service or any other thing of value, to be rendered periodically or on specified occasions to the transferer by the transferee, who accepts the transfer on such terms. According to the original petitioner Deorao Bajirao Thorat, it was an oral lease and the suit land was given in possession

The Commissioner of Income Tax-IV vs. M/s Pokarna Limited

The appeals are dismissed

ITTA/273/2012HC Telangana18 Feb 2025

Bench: P.SAM KOSHY,NARSING RAO NANDIKONDA

Section 260A

Section 80IA(8) requiring adoption of market value of goods in place of the actual - - 15 sale price in the cases of certain specified sales, and the transfer pricing rules, it held the Assessing Authority does not have the power to substitute the value for the actual sale price in the absence of any evidence of understatement of the value

The Commisioner of Income TAx-1 vs. Divya Shakti Granites Ltd.,

ITTA/178/2015HC Telangana04 Apr 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

Section 96

19 - RFA No.178 OF 2015 C/W RFA CROB NO.19 OF 2015 7.1 As already observed above, there are two agreements namely Exhibits P2 & P4 successively drawn on the same day, substantially with same terms & conditions, except as to price variation. In the former, price is shown to be Rs.74,80,000/-, whereas in the latter it is Rs.52

The Commissioner of Income Tax (IT and TP) vs. M/s. Idea Cellular Limited

Accordingly, the learned appellate authority has rightly dismissed the

ITTA/14/2021HC Telangana19 Oct 2023

Bench: P.SAM KOSHY,LAXMI NARAYANA ALISHETTY

Section 107

price. 27. In that view of the matter, as it is admitted case of the petitioner that the electricity generated in 540 MW Power Plant is used in the course of or furtherance of his business, which is evident from Form G provided by the taxpayer i.e. the petitioner herein, the petitioner would not be entitled for ITC to electrical

Suchirindia Infratech Pvt. Ltd vs. Dy. Commissioner of Income-Tax

Accordingly, the learned appellate authority has rightly dismissed the

ITTA/15/2021HC Telangana30 Apr 2021

Bench: T.VINOD KUMAR,M.S.RAMACHANDRA RAO

Section 107

price. 27. In that view of the matter, as it is admitted case of the petitioner that the electricity generated in 540 MW Power Plant is used in the course of or furtherance of his business, which is evident from Form G provided by the taxpayer i.e. the petitioner herein, the petitioner would not be entitled for ITC to electrical

The Commissioner of Income Tax IV vs. New Bombay Goods Transport

ITTA/249/2013HC Telangana11 Jul 2013
Section 4

transfer of property became taxable under Section 3(a) if the movement of goods from one State to another was under a covenant, or an incident, of the contract of sale and the property in the goods passed to the purchaser in another State. [S.R. Sarkar26]. If there was interruption of movement, and the snapping of the inextricable bond that

Commissioner of Income Tax, vs. M/s Y.Ramakrishna and others

ITTA/172/2003HC Telangana21 Jun 2011

Bench: V.V.S.RAO,RAMESH RANGANATHAN

Section 1Section 151Section 96

transfer has not been completed in the manner prescribed therefor by the law for the time being in force, ttre transferor or any person claiming under him shall be debarred from I 1i enforcing against the transferee and persons claiming under him any right in respect of the property of which the tuansferee has taken or continued in possession, other

The Commissioner of Income Tax IV vs. M/s. Nava Bharat Ferro Alloys Ltd.,

ITTA/392/2013HC Telangana05 Sept 2013
Section 14Section 14(1)(e)

prices were not settled. I have met Mr.Vivek Lall 2-3 times approximately during the last 5-7 years. I do not remember the place where these meetings were held.” 31. In cross-examination of Vivek Lall RW-1 recorded on 31st July, 2013 it was stated: RC.REV. 392/2013 & 394/2013 Page 32 of 46 “ …I had about 15 meetings with